Krinsky

As Internet technology has evolved over the past two decades, computer users have encountered a proliferation of chat rooms and Web sites that allow them to share their views on myriad topics from consumer products to international diplomacy. Internet bulletin boards, or “message boards,” have the advantage of allowing users, or “posters,” to express themselves anonymously, by using “screen names” traceable only through the hosts of the sites or their Internet service providers (ISP’s). One popular fornm is the financial message board, which offers posters the opportunity to communicate with others concerning stock trading, corporate behavior, and other finance-related issues.

The conversation on one financial message board devolved into scathing verbal attacks on the corporate officers of a Florida company, prompting a lawsuit by one of those officers, plaintiff Lisa Krinsky. Plaintiff attempted to discover the identity of 10 of the pseudonymous posters by serving a subpoena on the message board host, Yahoo! Inc. (Yahoo!). Defendant “Doe 6” moved to quash the subpoena, but the trial court denied the motion. Doe 6 appeals, contending that he had a First Amendment right…